What Should a REACH SVHC Declaration From a Supplier Include?
Founder & CEO Published Oct 16, 2026
A REACH SVHC declaration your customer will accept has to answer one question for each part you buy: does this article contain a substance from the EU Candidate List above 0.1% by weight? To answer it properly, the declaration needs six things:
- The exact manufacturer part numbers it covers, not “all our products”.
- A result per article, with the 0.1% w/w threshold applied to each component, not to the finished assembly.
- A named, dated Candidate List version. Today that is the list of 253 entries last updated on 4 February 2026.
- Each SVHC that is present, with its name, CAS number, and where it sits in the part.
- The manufacturer as issuer, not a distributor.
- A named signer and a date.
A blanket letter that says “we comply with REACH” fails most of these. It does not tie to part numbers, it often names no list version, and it usually applies the threshold to the wrong thing. That is why strict medtech and aerospace customers send it back.
What does REACH actually require a supplier to tell you?
The legal minimum is small. Article 33(1) of REACH says a supplier of an article that contains a Candidate List substance above 0.1% w/w must give the recipient enough information for safe use, and at least the name of the substance. There is no tonnage threshold. The duty starts on the day the substance is added to the list.
Note what the law does not require. A supplier only has to speak when an SVHC is actually present above 0.1%. Silence is not a breach on its own. But your customer cannot tell silence from ignorance, so they ask you for a positive statement on every part. You then have to ask your own suppliers for the same thing.
If you are a US contract manufacturer, you may have no direct REACH duty at all. Your EU importer or OEM customer does. The duty reaches you by contract. Your customer can only meet its Article 33 duty if every tier below it declares, so it writes REACH terms into its supplier requirements, and you pass them down to your suppliers.
What changed with the 2015 O5A ruling?
Before 2015, ECHA’s guidance read the 0.1% threshold against the whole article, while several member states read it per component. On 10 September 2015, the Court of Justice of the EU settled it in Case C-106/14, known as O5A. The court held that the threshold applies to each article incorporated as a component of a complex product. It also held that the Article 33 duty applies to every supplier in the chain.
For a board or a box build, that changes the math. Every resistor, connector, cable jacket, gasket, label, and fastener is its own article. A brass pin can contain lead above 0.1% of the pin’s weight while the lead is a trace in the whole assembly. Under O5A, the pin is what counts.
Lead is the most common hit in electronics. Many parts use a RoHS exemption to keep lead, and an exempt part can still be above 0.1% under REACH. Texas Instruments says this openly: its REACH statement notes that its RoHS-exempt parts contain lead above 0.1%. A part can be RoHS compliant and still trigger Article 33.
The ruling is also why enforcement found so many gaps. An ECHA Forum enforcement project checked articles that contained an SVHC above 0.1%. In business-to-business supply, 89% of those articles did not meet the information duty. Only about half of the companies checked applied the O5A ruling.
Why does a blanket supplier letter fail customer review?
A blanket letter is one signed page that covers everything a supplier makes. It is easy for the supplier and easy for you to file. It rarely survives review by a strict OEM. Declarations hosted on distributor sites show the usual defects:
| Defect | Example seen on distributor sites | Why a reviewer rejects it |
|---|---|---|
| No list version | A letter that certifies “no SVHCs” with no Candidate List date, and cites a repealed directive | Nobody can tell which substances were checked |
| Old list version | A 2020 letter that references the June 2020 Candidate List | About 40 entries were added since then |
| Wrong threshold basis | A letter that applies 0.1% to the assembled product | Contradicts O5A |
| Generic scope | One statement for every product the supplier makes | Different parts have different content |
| Wrong issuer | A distributor’s statement about another maker’s part | The distributor does not know the content. Mouser, for example, says it will not sign blanket REACH declarations |
| ”Free of” wording | ”SVHC-free” on a part that uses a RoHS lead exemption | Internally inconsistent |
Industry guidance has moved the same way. BOMcheck tells its suppliers that one signed statement can no longer cover all parts, because different parts contain different substances. Philips stopped collecting REACH letters from suppliers after each list update and moved them to part-level data in BOMcheck. Flex requires IPC-1752A data plus a signed certificate. Saab asks for full material declarations.
Smaller OEMs may still accept a letter. But if you serve three or more strict customers, plan for the strictest one. A part-level declaration can satisfy a customer that wants a letter. A letter cannot satisfy a customer that wants part-level data.
What fields should a part-level SVHC declaration include?
Use this as your acceptance checklist. If a returned declaration misses any required line, send it back with the reason named.
| Field | Required? | Pass condition |
|---|---|---|
| Manufacturer part number | Required | Matches the part number on your purchase order or approved vendor list, including revision where it matters |
| Issuer | Required | The part’s manufacturer, with company name and address |
| Candidate List version | Required | States the list date or entry count. Current today: 253 entries, 4 February 2026 |
| Region | Required | Names the EU list, the UK REACH list, or both. The two lists have diverged |
| Threshold basis | Required | 0.1% w/w per article. Not per assembly, and not per homogeneous material (that is the RoHS basis) |
| Result per part | Required | Yes, no SVHC above 0.1%, or a list of SVHCs present |
| SVHC name and CAS number | Required when present | Each SVHC above 0.1%, by name and CAS number |
| Location | Required when present | Which sub-part or component holds it, or whether it is in packaging |
| Concentration or range | Ask for it | Many OEM forms ask for weight or a percentage range |
| Part weight | Ask for it | Lets you and your customer compute presence in the finished product |
| SCIP number | Ask for it on EU-bound parts with an SVHC | Your EU customer needs it for its SCIP notification |
| Annex XVII restrictions | Ask for it | Stated separately from SVHC status. Restrictions bind articles directly |
| Wording | Required | ”Below 0.1%” is not the same as “free of”. The declaration should say which it means |
| Signer and date | Required | A named person who can answer for the data, and a date of issue |
Two checks catch most bad returns. First, compare the list version to the current list. Second, check any part that uses a RoHS lead exemption. If that part is declared SVHC-free, ask again.
Which format should you ask suppliers for?
Customers ask for one of three levels of detail. You should know which one you are collecting before you send the first request.
- Supplier letter. One statement, sometimes with a parts appendix. Lightest to collect. Weakest under review.
- Part-level SVHC declaration. An IPC-1752A Class C file or an OEM form that gives a REACH result per part number. This is the usual target.
- Full material declaration. IPC-1752A Class D. Lists every substance in the part. Hardest to get from small suppliers, who often refuse on trade-secret grounds.
Two customer groups widen the ask. Medtech OEMs work under EU MDR Annex I, section 10.4.1, which sets its own 0.1% test for certain CMR and endocrine-disrupting substances in some devices. An SVHC-only declaration may not fully cover it. Aerospace primes often want data against the IAEG declarable substance list in IPC-1754 format. Ask each customer which format and list they need before you design your supplier request.
Who at the supplier should sign it?
Ask for the person who owns product compliance or quality at the manufacturer. A sales rep can pass the request along, but sales staff rarely know what is in the part. A distributor contact cannot sign for another company’s part.
Small custom suppliers often have no compliance person at all. Machine shops, platers, anodizers, molders, and harness houses usually publish nothing. For them, ask the quality manager or owner. Give them a short form with the fields above. Tell them which list version to declare against. Many will answer once the ask is clear.
What should you do with the declaration once it passes?
File it against each part number it covers, with the list version and date it names. That record is your evidence. When you answer your own customer, you sign your own declaration. Your suppliers’ declarations support it. They do not replace it.
Be precise in what you assert. If a part’s status rests on a supplier’s word, say so. “Per supplier declaration dated 12 March 2026, against the 253-entry Candidate List” is a statement you can defend in an audit.
When the Candidate List changes, every declaration that names an older version becomes stale. See what to re-ask suppliers after a Candidate List update for how to handle that.
TL;DR
Does REACH require a declaration from every supplier?
No. Article 33 only requires information when an SVHC is above 0.1% in an article. Your customers require a positive statement anyway, so you need one from each supplier.
Does 0.1% apply to the whole product or each part?
Each part. The 2015 O5A ruling (C-106/14) applies the threshold to every article built into a complex product.
Which Candidate List version should a declaration name?
The current one. As of 16 October 2026, that is 253 entries, last updated 4 February 2026.
Is a blanket REACH letter ever enough?
Some smaller customers accept one. Strict medtech and aerospace OEMs usually want part-level answers tied to a list version.
Sources
- REACH, Regulation (EC) 1907/2006, consolidated text. Article 33 is the supply chain information duty. Article 3(3) defines an article.
- CJEU, Case C-106/14 (O5A), 10 September 2015. The 0.1% threshold applies to each component article.
- ECHA Candidate List table. The authentic list. Shows the 4 February 2026 update and 253 entries.
- ECHA guidance on requirements for substances in articles. ECHA’s reading of Articles 7 and 33.
- ECHA Forum pilot project on substances in articles. Enforcement results on Article 33.
- IPC materials declaration standards. IPC-1752A classes and IPC-1754.
- BOMcheck REACH guidance. Part-level declarations and the Philips example.
Bridgecurrent sends these declaration requests from your own email, follows up, finds a better contact when someone goes quiet, and sends back any declaration that fails the check. See pricing.